Cal/OSHA publishes tips for monkeypox

As monkeypox (MPX) continues to be a problem throughout California, Cal/OSHA has issued guidance to help protect employees. However, this policy only applies to workplaces that fall under the ATD (Aerosol Transmissible Diseases) standard, which is notable given that the policy itself states that “MPX is primarily acquired through close or direct contact with an infectious rash, lesion, scab, or bodily fluids spread”. However, the guidance also states that “the virus can become airborne when changing or handling contaminated laundry.

Workplaces covered by the Cal/OSHA ATD standard include:

  • hospitals
  • Competent care facilities
  • Clinics, doctor’s offices and other outpatient medical facilities
  • Home care
  • Long-term care facilities and hospices
  • medical support services
  • paramedics and ambulance
  • ambulance
  • Homeless shelters (including migrant shelters)
  • Drug treatment programs
  • Laboratories performing procedures with materials that contain, or may reasonably be expected to contain, aerosol-borne pathogens

The guidelines set out different requirements for outpatient clinics, dental offices, hospitals and other employers that fall under the ATD standard. Because this guide is very specific, we recommend checking the requirements directly against the Cal/OSHA guide linked above.

The guidance also provides that all employers covered by the ATD standard must provide and ensure employee use of respirators, which are defined as fitness-tested, NIOSH-approved particulate respirators with an N95 filter or higher, the:

  • Enter a room where there is a case or suspected case of airborne infectious disease, including MPX;
  • Enter an airborne infection isolation room or area used for airborne infection isolation;
  • being present at procedures or services relating to a case or suspected case of an airborne infectious disease, including MPX;
  • Repair, replace, or service air systems or equipment that may contain or generate aerosolized pathogens;
  • Work in an area occupied by a case or suspected case of an airborne infectious disease, including MPX;
  • being present during the decontamination of an area where an infected patient or client was located;
  • Work in a place of residence where there is a known case or suspected case of an airborne infectious disease, including MPX;
  • present during the performance of aerosol-generating procedures in patients suspected or confirmed to have an airborne infectious disease such as MPX (powered air-purifying respirator or better);
  • are present during the performance of aerosol-generating procedures on cadavers that may be infected with aerosol-borne pathogens (powered air-purifying respirator or better);
  • Perform a task for which the biosecurity plan or exposure control plan requires the use of respirators;
  • Transport a case or suspected case of an airborne infectious disease, including MPX, within a facility or in a closed vehicle if the patient or client is not masked; or
  • Handle laundry potentially contaminated with MPX unless effective procedures are in place to prevent the release of virus particles.

Insured employers are also required to provide personal protective equipment (PPE) to employees who have been exposed to a person with or suspected of having MPX, including gowns, gloves and eye protection.

Finally, affected employers must implement written procedures for incidents of exposure (aka “significant exposure”), which are further defined in the guidance. For such incidents, the following obligations apply under the ATD standard:

  • Notify workers who have had significant exposure of the date, time, and type of exposure.
  • Provide a post-exposure medical evaluation by a physician or other licensed healthcare professional (PLHCP) knowledgeable of MPX, including appropriate vaccination, prophylaxis, and treatment.
  • Offer post-exposure prophylaxis (i.e. vaccination against MPX) as soon as possible; often through the local health department.
  • Report exposure to local health department.
  • Remove the employee from the workplace if precautionary removal is recommended by the PHLCP or local health officer. During the precautionary removal, maintain the employee’s salary, rights, benefits, etc.

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